Free Statement - District Court of Arizona - Arizona

UNITED STATES DISTRICT COURT
DISTRICT OF ARIZONA
CASE NO. CIV 03 2353-PHX-DGC
CENTURY 21 REAL ESTATE CORPORATION,
DARYUSI-I B. MOTLAGH ANI) JANE DOE MOTLAGH, HUSBAND AND WIFE; ·
INTEGRITY ASSURANCE, I
EXHIBIT TO CENTURY 21 REAL ESTATE CORPORATION’S: (1) RENEWED
MOTION FOR SUMMARY JUDGMENT ON ITS BREACH OF CONTRACT
AND UNJUST ENRICHMENT CLAIMS; AND (2) MOTION FOR SUMMARY I
JUDGMENT ON COUNTERCLAIMS
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EXHIBIT 8 I
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Case 2:03-cv-02353-DGC Document 78-13 Filed O7/O7/2006 Page 1 of 3 l I

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· »t__ _,_,,,; t?l =t.l 7 g
,i }Real Estate Corporation · ;
- 10 Sylvan Way ’ O Q
Parsippany, New Jersey 07054 .. - _
Business (973) 428-9700 · ‘’’` l
Fax (973) 496-7090 · l
VlA AIRBORNE EXPRESS ‘
_ April 27, 1998 _ g
Daryush l\/lotlagh as ` . - _ .
CENTURY 21 Assurance Realty
14175 W. indian School Rd.
Litchfield Park, AZ 85340 ` ‘
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7 Re: A/R No. 6272 — Litchfield Park, AZ A
. ` Dear Nlr. Daryush Motlagh; -
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This letter will comirm the terms of the payment plan which has been agreed upon between
A Assurance‘Realty (the "Franchisee") and CENTURY 21 Real Estate Corporation, (“Company”) l
relating to amounts owed by Franchises to companyunder its CENTURY 21 Real Estate l
Corporation Franchise Agreement (the "Agreement"). The outstanding balance on Franchisee
` account which is subject to this payment plan is $17,109.23 which represents all delinquent fees
V and charges owed by Franchisee through April 27, 1998. This amount does not include any
’ balances found pursuant to any future audit covering this period. An analysis of this liability with
supporting detail is attached for your reference. After you review, please contact me if you
believe any amounts are incorrect. By signing below you, acknowledge that you will be
individually liable for all amounts due under the terms of this payment plan. 7 -
The payment plan will be as follows: l
MONTHLY PAYMENT MONTHLY
DUE DATE PAYMENT AMOUNT
April 27, 1998 $3,399.80 - Received A .
‘ A May 31, 1998 - October 31, 1998 $2,284.94 + Current Fees .
All monthly payments must be in our 0fHce on or before the above—specitied dates- If payment ‘
is not received by the “due dates", this plan will become null and void and the entire outstanding
‘ balance will become due in full. The continued participation of your office and agents in the
CNTURY 21 Awards Program is contingent upon your honoring the terms and conditions of this “
payment plan. Additionally, this payment plan must be paid in full on or before the CENTURY
21 Cash incentive Bonus issuancedate to be eligible to receive any CENTURY 21 Cash
incentive Bonus.
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Please- be reminded that in order for your CENTURY 21 Office to be in good standing
. Franchisee- rnust pay all obligations due under the Agreement including royalty fees, service
fees, ad fees, franchise tees, miscellaneous invoices, and promotional billings etc., in addition to _
{ the monthly installment as outlined in the above plan.
K; .
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A Cendant Company C2] -00 1
_ Case 2:03-cv-02353-DGC Document 78-13 Filed O7/O7/2006 Pag 26%% lf}

.2+., A A A Q" Y A 8 7 . l
April 27, 1998 g `
CENTURY 21 Assurance Realty page 2 7
With the return of the signed copy of this letter Franchisee agrees, on behalf of itself, its
partners, ofticers, employees, directors, shareholders and any Guarantor(s) of the
A Agreement, and the successors and assigns of each of them, hereby release and hold
harmless the Company, its ofticers, employees, agents, directors, shareholders, and the · l
. successors and assigns of all of them from any and all liability cost or expense, arising A
‘ from any claims, or causes of action which Franchisee has or may have against
Company under the Agreement as of this date hereof.
. n All PAYMENTS and correspondence should be sent via OVERNIGHT MAIL to the i
following:
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. CENTURY 21 Real Estate Corporation _ i i
‘ __ 10 Sylvan Way `
Parsippany, NJ 07054 r
‘ Attn; Jean Wenz i
y i
Please acknowledge acceptance of this letter agreement by signing where indicated X
g below and returning one original to me with your payment. ‘ r l
> if "y V3}: truly yours, ` .
Ja on B0
Fr nchise Collections -
l Agreed to:
CENTURY 21 Assurance Realty _ y
Mr. Dal u otlagh — C21 Assurance Realty i
A A i
Agreed t {F . g
_. By: _ ‘t‘r
ll/lr. Da "us y otlagh-Broker .
n _ . Attachments _ I
i cc: J. Wenz .
_ C. Torian ·
6. K. Link ‘ I
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Case 2:03-cv-02353-DGC

Document 78-13

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Case 2:03-cv-02353-DGC

Document 78-13

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Document 78-13

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